Playing by the Rules of Marketing to Children

If you’re creating products that are meant for children, you probably already know that children don’t process sell messaging in the same ways as adults. As a responsible marketer, it’s important to take steps to protect your audience from the very marketing techniques that have proven to be so effective with older audiences.

It’s equally important to understand the unique climate of regulatory and self-regulatory scrutiny that exists around marketing to children. There are a variety of groups and concerns to be aware of and to work through in order to get your message across in the best light. It’s a balancing act, but it can be done. Here are just some of the stakeholders that you need to be aware of:

Regulation:The Federal Trade Commission (FTC)
The FTC works to prevent deceptive or unfair business practices. As marketers, you know that your messaging needs to be truthful, not misleading or deceptive. However, the threshold for deception is much lower when you’re dealing with a child consumer. Start with plain language, replicable demonstrations and simple, truthful statements. If you need to clarify your messaging with disclaimers, consider whether or not there’s a way to simplify the statements to make them easy to understand without any fine print.

The FTC also enforces the Children’s Online Privacy Protection Act (COPPA), which regulates how data can and can’t be collected through websites and online services directed in whole or in part to children under the age of 13.

Federal Communications Commission (FCC)
The FCC is responsible for regulating interstate and international communications over radio, TV, wire, satellite and cable. They implement the Children’s Television Act, which – among other things – regulates the amount of time that can be spent on advertising during each hour of programming originally produced and broadcast for children 12 and under.

Self-regulation:Children’s Advertising Review Unit (CARU)
CARU has industry self-regulatory guidelines that they apply to national advertising intended for children under 12. In part, they echo the standards of the Federal Trade Commission, but they go further in some areas, and provide general guidance around language, sell techniques and product presentations. CARU evaluates advertising through the lens of the child viewer and will consider messaging from the perspective of that vulnerable and impressionable group. CARU also reviews websites and apps for compliance with COPPA.

Children’s Food and Beverage Advertising Initiative (CFBAI)
The CFBAI aims to help promote healthy diet and lifestyle choices for children, and is concerned with what foods and beverages are marketed in advertising that is primarily directed to children under 12. They lay out specific nutrition criteria for program participants.

Note that CARU also has specific guidelines around food and beverage marketing, with a focus on how the products are depicted and described in advertising.

Motion Picture Association of America (MPAA)
The MPAA rates movies, but they also review and approve advertising intended for children. In addition, they handle referrals from CARU around advertising of PG-13 movies to children.

Entertainment Software Rating Board (ESRB)
The ESRB rates video games and some gaming apps. They also have a set of advertising guidelines that specify how and when game ratings must be disclosed in advertising. In addition, the ESRB lays out guidelines explaining where games rated T (for Teen) and up may be advertised, based on defined audience composition thresholds.

These are just a few of the groups invested in ensuring that advertising and marketing to children is handled responsibly. There are others, including a variety of advocacy groups that are scrutinizing advertising and marketing for their own concerns, and that may call you to task if you misstep in certain areas.

It is, indeed, an alphabet soup of organizations to navigate. However, there are some fundamental concepts that apply throughout, and understanding the basics will help you create effective marketing campaigns that are ethical, effective, and demonstrate responsibility to young consumers. That, in and of itself, can be the start of a good business model for companies invested in creating products and marketing intended for children.

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When engaging with the youth market, operating responsibly can be your biggest business advantage. PlayWell's mission is to partner with clients to successfully navigate the compliance world and drive your business forward.